12. September 2017 Profit participation rights at fixed rate is interest under ... In a dispute between Germany and Austria on the right of taxation of payments from registered certificates the ECJ held that such interest should be taxed only in the country of residence of the beneficial owner unless such debt-claims explicitly provide the creditor with a participation in the debtor’s profits. Kategorien: European Court of JusticeSchlagwörter: fixed-term debentures, interest, profit ...
05. Januar 2011 Loan interest subject to profits is profit sharing under Aus ... The Supreme Tax Court has held that payment of interest only if the payer remains profitable means that the payment is profit sharing and subject to withholding tax under the Austrian treaty. Kategorien: Supreme Tax Court casesSchlagwörter: loan interest, Profit-sharing interest, ...
